Kevin,

On Sep 13, 2013, at 2:42 PM, Kevin Kargel <[email protected]> wrote:
> I still don't see how this is going to be enforceable. To my eye it would 
> entail getting geo-data for all last mile routers that service IP's under 
> ARIN control and having someone or a sophisticated AI bot continuously 
> scanning the BGP tables to enumerate and verify the geo-locations of the 
> endpoints.

Why wouldn't an assertion by the applicant that they run a network in the ARIN 
region and perhaps a traceroute or two be sufficient to meet the "operating a 
network located in the ARIN service region" requirement?

> If the idea is just to ask people if they are in the ARIN governance area and 
> make them promise to never move offshore (knowing it will not be subsequently 
> policed) then I submit that the algorithm is way too easy to game by 
> unscrupulous operators and will end up being a token policy that creates more 
> bureaucracy and trouble for legitimate operators.  

I don't see this being significantly different than gaming the "operational 
needs" requirement. I think the issue here is establishing a policy basis upon 
which violations, when detected, can be addressed. If it is discovered that 
someone is getting addresses to stockpile them for later sale, ARIN policy 
exists to allow ARIN to revoke those addresses.  This draft policy is saying 
that if someone is getting addresses for use outside ARIN's region, there would 
be a policy to allow ARIN to address that issue.

And, FWIW, I'll note that both AfriNIC and LACNIC (the remaining RIRs that have 
not gone into "last /8" policy) require companies to demonstrate in-region 
legal status and network usage. 

> If you can figure out a way to enforce *and* implement it I would support the 
> policy, but until that time I have to vote "nay".  I suspect that even if it 
> were implemented enforcement would only be possible if it were written with 
> an anti-grandfather clause.

Wait, I liked my grandfather... :) (sorry, not sure what an 'anti-grandfather 
clause is)

Regards,
-drc

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